DI NT (CASE NAME: Assistant Secretary for Fair Housing & Equal Opportunity v. Facebook, Inc. ‘CASE NUMBEI 1. Complainant: Assistant Secretary for Fair Housing & Equal Opportunity US. Department of Housing and Urban Development 451 Seventh Street, SW, Suite 5100 ‘Washington, DC 20410 2 Other Aggrieved Persons: Undetermined at this time. 3. The following is alleged to have occurred or is about to occur: Discriminatory advertising statement and notices. 4. The alleged violation occurred because of: Race Color Religion Sex Familial Status ‘National Origin Disability ‘Address and location ofthe property in question (or ifno property is involved, the city and state where the discrimination occurred): ‘Throughout the United States. 6 Respondents: Facebook, In. Mark Zuckerberg, CEO 1601 Willow Road ‘Menlo Park, CA 94025 7. The following isa brief and concise statement of the facts regarding the alleged violation: ‘The Assistant Secretary for Fair Housing and Equal Opportunity, on behalf ofthe Secretary ofthe U.S. Department of Housing and Urban Development, files this‘Secretary-intiated complaint of housing discrimination as authorized by the Fair Housing, Act at 42 US. § 36104@( (AV). Facebook unlawfully discriminates by enabling advertisers to restrict which Facebook users receive housing-related ads based on race, color, religion, sex, familial status, national origin and disability. Facebook mines extensive user data and classifies is users based on protected characteristics. Facebook's ad targeting tools then invite advertisers to express unlawful preferences by suggesting discriminatory options, and Facebook effectuates the delivery of housing-related ads o certain users and not others based on those users’ actual or imputed protected tats. ‘As of July 24, 2018, Facebook's ad targeting tools enable edvertisers of housing and hhousing-related services to discriminate in the following non-exhaustive list of ways: ‘© Facebook enables advertisers to discriminate based on sex by showing ads only to men or only to women. ‘+ Facebook enables advertisers to discriminate based on disability by not showing ads {o users whom Facebook categorizes as interested in “assistance dog,” “mobility scooter,” “acessiblity” or “deaf culture, ‘+ Facebook enables advertisers to discriminate based on familial status by not showing ‘ads to users whom Facebook categorizes as interested in “child care” of “parenting, ‘or by showing ads only to users with children above a specified age. ‘+ Facebook enables advertisers to discriminate based on eligion by showing ads only ‘to users whom Facebook categorizes as interested inthe “Christian Church,” “Jesus,” “Christ” or the “Bible.” ‘+ Facebook enables advertisers to discriminate based on aational origin by not showing ads to users whom Facebook categorizes as interested in “Latin America,” “Southeast Asia,” “China,” “Honduras,” "Somali.” te "Hispanic National Bar Association” or "Mundo Hispanico. ‘+ Facebook enables advertisers to discriminate based on ace and color by drawing @ zd line around majority-minority zip codes and not showing ads to users who live in those zip codes. Facebook markets its ad targeting platform as useful tool for providers of hou related services. For example, Facebook promotes its ad targeting platform with “success stories” for finding “the perfect homeowners,” “reaching home buyers,” “attracting renters” and “personalizing property ads.” See www facebook com/business/success! quadrant-homes (visited Aug. 8, 2018); www facebook convbusiness/successfhomesnsp (visited Aug. 8, 2018); www. facebook com/business/success/apartment-list (visited Aug. 8, 2018) ‘The alleged policies and practices of Facebook violate the Fair Housing Act based on race, colo, religion, sex, familial status, national origin and disability. ‘The most recent date on which the alleged discrimination occurred: Ongoing.9. ‘Types of Federal Funds identified: None. 10. The acts alleged in this complaint, if proven, may constitute a violation of the following: ‘Subsections 804(a), 804(b), 804(c) and 804(F) of Title VII of the Civil Rights Act of 1968, as amended, [ declare wnder penalty of perjury that I have read this complaint (including any attachments) and that itis Bue